Day 1 - Session IV – Drafting: Drafting the FIC’s intake and request SOPs

Three products:

  1. Contents/Outline – SOP
  2. Workflow (detailed)
  3. Fleshing workflow out into bullet points
  4. Based on proclamation – what intakes?
  5. Who are sources? What do we expect from whom?
  6. How to collect them – means?
  7. Who does what? Ex: banks, supervisory or other agencies, recipients
  8. What type of intake? What type of activity for every intake?
  9. Ex: What type of activities for STR?
  10. Who does what?
  11. When reported/received/checked against verifications (completeness)?
  12. How? – mechanism
  13. What kind of guidelines to sources and recipients?

2. Workflow

(DC to draw diagrams from TAD)

Is an STR complete? Criteria:

  1. Branch
  2. Contact person – signed by branch manager
  3. Contact Address
  4. Telephone number
  5. Fax
  6. Email
  7. If from head office only, already know compliance officer. Head office reports ST from different branches, then forward to FIC. Final decision of making this STR is from the branch.
  8. Fields completion – need an auto mechanism to test whether require fields are filled in. System to flag incomplete
  9. Mandatory fields should have a clear mark (ex: red box for mandatory)

Are all mandatory fields completed?

If incomplete:

  1. Standard template for correspondence back to sender of STR
  2. Ex:
  3. To: Branch
  4. Address
  5. Subject: Incomplete STR
  6. Body: Include check boxes next to fields – check which ones are incomplete

Opinion of reporting entity-the compliance officer (who submitted report)

Occupation of the individual who conducted transaction

If yes, complete STR (in terms of all mandatory fields):

  1. Goes to Deputy Director General

[*FIC has to receive all STRs and analyze them. FIC does not have the right to completely refuse. Without additional information, FIC files it – This is not a standard procedure.]

When Deputy Director General receives the complete STR, she decides if it is suspicious based on:

  1. Verification: Substance of indicators of a STR
  2. Prioritization: Weight of indicators
  1. The DDG analyzes all STRs.
  2. If it is an STR, which STR should be prioritized?
  1. Make first assessment based on risk matrix.

Risk Matrix – Kamlesh to provide copy of matrix with ratings.

[Risk Matrix background. Usually done by computer system such as goAML and can set FATF typology criteria ex: TF typologies. ]

Impact

HH 100% risk

Likelihood

LL

  1. If low-risk STR, how to handle it?
  2. Reference/Database: Keep on file as information and never delete transaction reports. “Intelligence never dies”.
  3. Information-sharing: FIC provides as information to another entity working on related case.
  4. [FIC mandate – Can automatically request bank to block account for up to three days.]
  5. Ex: NISS responsibility in relation to terrorist activities. Consult NISS to see if there are related cases - FIC to request additional information from banks to see if they have similar activity as a supplementary report (no analysis).

How would STR go to database? – SOP needed

How to receive, handle validation of and add CTRs to database? What about for cross-border transaction reports? Wire transfer reports? – SOP needed

STR flow: - need to set timeframe– SOP needed

Source

Financial information follow-up

DDG

Analyst

CTR flow:need to set timeframe– SOP needed

Source

Financial information follow up

Examiner/verifier = analyst

Database == sent to analyst

FIC already has:

  1. Format for STR (see: is an STR complete?)
  2. Format for CTR

Next steps:

  1. Software selection and purchase for FIC
  2. Options:
  1. Visualink (FINCEN, AMLO use)
  2. I2
  3. goAML (Mauritius fully integrating software in Jan. 2014)
  4. “CLEAR” (TBC – to look up)
  5. Text Retrieval system (old Mauritius software – “internal google”)
  6. Show links in terms of cases involved – analyst then extract into I2 chart
  1. Software criteria
  2. Mandatory fields
  3. analysis capacity